Trade Compliance

SEC Adopts New Insider Reporting Rules for Foreign Private Issuers

The SEC has adopted new rules requiring directors and officers of foreign private issuers (FPIs) to report their beneficial ownership and trades in the issuer's equity securities. These changes, effective March 18, 2026, align FPI reporting with that of domestic issuers and aim to increase market transparency.

DOJ Rules on Bulk Sensitive Personal Data Transfers

The Department of Justice has issued new regulations (28 CFR Part 202) implementing Executive Order 14117, restricting the bulk transfer of sensitive personal data, including health and genomic data, to countries of concern. These rules add a layer of compliance beyond HIPAA for organizations handling international data transfers.

Florida AG Forms Unit to Combat Foreign Data Threats

The Florida Attorney General has established a new unit, the Consumer Harm from International Nefarious Actors (CHINA) Prevention Unit, to investigate and prosecute foreign companies misusing Floridians' personal data. The unit will focus on companies linked to foreign adversaries, particularly in the healthcare sector, and will investigate money laundering and cyber fraud.

Multinational Employers: Large-Scale Workforce Reduction Mistakes

This article highlights common mistakes multinational employers make when planning large-scale workforce reductions in 2026. It emphasizes the critical need for pre-announcement consultations with works councils and government bodies in various jurisdictions to avoid invalid terminations and penalties.

Trade Case Filed Against Chinese Truck Bed Cover Imports

U.S. producers RealTruck, Inc. and others have filed petitions with the Department of Commerce and International Trade Commission seeking antidumping and countervailing duties on truck bed covers imported from China. The petitioners allege that these imports are being sold below fair value and are unfairly subsidized, causing injury to domestic producers.

Federal Circuit Allows IEEPA Tariff Refund Litigation to Resume

The U.S. Court of Appeals for the Federal Circuit denied the government's request for a stay, allowing litigation seeking refunds of tariffs imposed under IEEPA to resume. The decision remands the case to the Court of International Trade, where over 2,000 similar cases are pending.

DOJ Names Chicago U.S. Attorney's Office Lead Partner on Trade Fraud Task Force

The Department of Justice has selected the U.S. Attorney's Office for the Northern District of Illinois as a lead prosecutorial partner for its Trade Fraud Task Force. The task force aims to pursue parties evading federal customs laws and smugglers of prohibited goods, utilizing civil and criminal enforcement tools.

February 2026 Sanctions Developments

Hughes Hubbard & Reed LLP published an update on February 2026 sanctions developments, highlighting the largest individual civil monetary penalty, a penalty against an academic institution, and designations signaling pressure on Nicaragua. The update provides insights into recent enforcement actions and potential future sanctions targets.

IRS Guidance on Foreign Entity Material Assistance for Clean Energy Tax Credits

The IRS issued Notice 2026-15 providing interim guidance on determining material assistance from prohibited foreign entities for clean energy tax credits. The notice outlines rules for the Material Assistance Cost Ratio (MACR) and includes a request for comments.

Treasury and IRS Simplify Currency Rules for Businesses

The Treasury and IRS have issued Notice 2026-17, announcing proposed regulations to simplify Section 987 currency rules for businesses. Key changes include an equity and basis pool method election and modified rules for recognizing suspended losses, aiming to reduce compliance burdens.